Early Warning Signs… And Resources ORRICK, HERRINGTON & SUTCLIFFE 213/ BACKGROUND INTELLIGENCE, INC. 213/

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“...not by the hand of Pablo Picasso.”

D epartment OF J ustice

 harvesting scam  Financial aid scam  Student aid heist  Textbook Scam  Website Hackers  U.S. News College Rankings Manipulation  Fake college enrollment  Terrorist Visas through fake college enrollment  Unqualified admissions for privilege  Student loan scandal

Based on Top Biggest College Scams  Former and current students  College presidents, university officials, trustees, director of admissions, and other administrators  International gangs  Politicians  Financial aid and lending institutions  Other, including grandmothers and multi- generational swindles

 Organized fraud rings and financial aid fraudsters target  University of Phoenix: 850 potential fraud schemes reported to federal authorities since 2009 (prosecution rate: approximately 25%)

Depends on:  Type of fraud or loss  Who is involved  Evidence  Corroboration from others Get facts:  Before making a major decision  Before reacting to a situation

 Follow your institution’s protocol and published Policies and Procedures Manual  Contact legal counsel (attorney-client privilege)  Get facts: fully investigate the incident with the assistance of independent professionals THEN…you can start to make intelligent decisions

 Interviews  Proprietary databases*  Public records  Internet and social networking sites  Surveillance, dumpster diving, undercover

 Verifying identities  Finding assets  Defining complex business structures and personal interrelationships  Identifying potential “bad guys” or people in cahoots with the bad buys  Clarifying anomalies  Identifying potential witnesses  Obtaining documentation and independent verification for self-reported “facts”

 Most fraud and white collar crime goes unreported  Only 8% of cases reach proper authorities  MEANING: they’re out there to do it again (Source: National Public Survey on White Collar Crime)

 Critical to understand:  The nature and extent of the fraud  The individual(s) involved  Domestic or international

 No panacea for dealing with fraud  Lengthy, dedicated, persistent effort  Leadership and coordination required

Fraud took place: June 2011  PRO-ACTIVE STEPS TAKEN  PROBLEMS  Unknown identity of the fraudster(s)  Unknown nature of the scam  Identifying other victims  Unknown potential sources of remuneration, due to all of the above

Tuesday, December 13, 2011 “Olivia, Per my office’s investigative supervisors, this case doesn’t meet our guidelines or the guidelines for the U.S. Attorney’s Office. If you get more victims and a higher dollar loss, please let us know.” Special Agent Los Angeles Field Office

 Community Colleges are adopting pro- active strategies  Challenges to financial aid applicants

 Disbelief…  Whistleblowers and victims are always placed in a challenging position  Victims are embarrassed at being duped MOSTLY…WANT TO AVOID BAD PRESS

Olivia Robinson BACKGROUND INTELLIGENCE, INC. 213/ Mark Mermelstein ORRICK, HERRINGTON & SUTCLIFFE 213/